FDA Report Cards: School Lunches

While the GMA has endorsed the idea, in principle, we struggle to imagine the consumer implied by the concept. Let us imagine the kind of person for whom such a report card is designed:

This is a consumer who analyzes health claims of new products in a scientific fashion, at the shelf.

This is a consumer who understands the difference between "Moderate Evidence," "Some Evidence" and "Little Evidence" when contemplating a health claim.

This is a consumer who believes that this kind of evidentiary information, in the absence of any contextual information, is to be understood literally.

This is a consumer who looks up to the FDA, the government, public policy officials and food companies, to tell them what "healthy" means and what is healthy, or unhealthy, about the food they love.
Our ethnographic research shows time and time again that most Americans don't really care what the FDA says about the healthiness of food and beverage products. And they don't care about the food pyramid as they eat during the day or when they go grocery shopping. They value the FDA to regulate the safety of our food supply, not its relative healthiness or the truthfulness of marketing campaigns. Consumers don't feel dependent on the government to be skeptical on their behalf.

The consumer that this report card concept implies is a consumer that, in our opinion, simply doesn't exist. Consumers do not, and can not, act as little food scientists in the harried process of shopping, cooking and eating as everyday people. Consumers also do not look up to food companies to learn how to be healthy or to the government to protect them from the former's "misleading" health claims. They see themselves as the final arbiter of the legitimacy of health claims, even when they simply don't have the knowledge necessary to really be making such determinations. This will always be the case, to some extent, just as many consumers will never floss their teeth, no matter how many lectures they receive from dental hygienists.

In a culture where consumers are increasingly empowered and defining themselves as the expert, marketers and food companies should not over-estimate the role of objective, scientific truth in the CPG transaction. What matters is what consumers believe to be true, because this is generally what they will act upon as purchasers, regardless of contradictory information they've heard from the FDA. The only times that FDA contradictions of food-related health claims tend to correlate highly with consumer behavior are when 1) the FDA issues safety related warnings (e.g., "you might die if you eat this..." and 2) when a consumer hasn't yet come to believe a certain food-related health claim him/herself. In the latter case, the FDA ends up reassuring them that, "I was right after all about that nonsense."

We find that as consumers become more wellness-oriented, they often discount the FDA in favor of trendier sources of nutrition information. While the latter sources may not be scientific at all, they become symbolic aids in the pursuit of a health lifestyle that they define, not a healthy lifestyle defined by big business or by the government.

Lesson for CPG Food companies

CPG companies at the cusp of entering the health and wellness arena need to think less literally about their opportunities and learn how to analyze what different kinds of wellness consumers are looking for in terms of "health cues," not what is objectively healthy. Indirect cues of healthiness - freshness, naturalness, local, minimally processed, artisanal, indigenous, etc. - are not only more effective marketing tools but they also help companies steer clear of the FDA's ire by making misleading or weakly supported health claims in the effort to be the guys with next "big claim."

The ever constant pursuit of a scientifically valid functional food health claim is draining the resources of CPG food companies, when more vague health cues are all that is necessary and can save companies from legal problems that inevitably arise when the "science" changes surrounding their product's health claim and they have thousands of facings all across America suddenly making "false" claims.

This is why we advise against overly targeted health claims at all for CPG food products, which tends to invite the ire of the FDA and regulatory agencies and motivates them to come up with crazy ideas like a report card.

Instead, we advise that companies think about:

The story behind its production and ingredient sourcing (where did we get our raw ingredients and how hard did we work to find them?) and
Grounding their "healthy" products in what the consumer sees as the natural order of things, not the order of nutritional science and food engineering

Harvey Hartman - Founder, Chairman & CEO of The Hartman Group (hartman-group.ecnext.com/).
An author, business school lecturer and former Fortune 500 senior executive, Harvey Hartman is a nationally recognized expert on American cultural change and the consumer activities.